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The ABC & AML Manual covers areas such as: 7. CODE OF CONDUCT
i. The contracting and procurement process The Code of Conduct (Code) applies to every employee,
ii. Offering and receiving gifts and hospitality officer, and director in HRC as well as contract employees
working for HRC. Contractors and consultants who are
iii. Conflicts of interest agents of, or working on behalf of, or in the name of HRC
iv. Facilitation payments (through outsourcing of services, processes or any business
activity), are required to act consistently with the Code
v. Funding social investment, donation and sponsorship
when acting on HRC’s behalf. Contractors and consultants
vi. Political payments and activities are also made aware of the Code as it applies to their
vii. Recruitment dealings with HRC employees.
The ABC & AML Manual and its contents have been The Code outlines the following:
communicated to all employees via memorandum, HRC’s
intranet and in-house training. The same has also been • Our responsibilities and a guide to ethical decision
communicated to all vendors, suppliers, contractors and making.
any third parties that have business dealings with HRC. • The standards of good behaviour that HRC expects from
Employees and parties having business dealings with every employee, all contractors and all consultants as
HRC have also been requested to sign a declaration well as contract employees.
of their commitment to comply with the ABC & AML • That we have the right to expect the same standards of
Manual and to disclose any conflict of interest via HRC’s behaviour from our colleagues.
annual declaration process. Business associates and • The system for handling of sensitive information and
senior management are subject to integrity due diligence HRC’s Intellectual Property.
checks from time to time.
• Guidelines to help in keeping our business interactions
The ABC & AML Manual and HRC’s General Business legal, ethical and professional, ensuring that we protect
Principles are accessible to the public on HRC’s ourselves from any suspicion of wrongdoing and to
corporate website. safeguard HRC’s reputation.

b. BUSINESS INTEgRITY ACTIvITIES
8. INFORmATION AND COmmUNICATIONS TEChNOLOgY
In year 2020, various activities were organised online to
strengthen the culture of business integrity within the Information and communications technology are
Company. extensively deployed in HRC to automate work processes
where possible and to efficiently collect and report key
During the first week of October 2020, the Risk & business information.
Integrity Department organised the annual Business
Integrity Week in conjunction with World Ethics HRC is certified under the Information Security Management
Day 2020, comprising of forums, an integrity quiz, Systems (ISMS), MS ISO / IEC 27001: 2013 and shall
ethical and information system e-learnings and a virtual continue to enhance its information and communication
integrity exhibition. systems to ensure that it can act as an enabler to improve
business processes, work productivity and decision making
6. COmPLIANCE mANAgEmENT throughout the Company.
The Management team led by the CEO is responsible for 9. EmPLOYEES PERFORmANCE mANAgEmENT
ensuring day to day operational compliance within the
Company. HRC selects individuals for employment through a
structured recruitment process. The professionalism and
HRC’s compliance management includes compliance to all competency of employees is continuously enhanced
relevant laws, regulations, rules and guidelines. It also covers through a structured training and development programme.
risk-based compliance to the Company’s internal policies,
procedures, and code of conduct. A performance management system is in place which
measures employee’s performance against agreed goals on
In 2020, no major non-compliance was encountered. an annual basis.